[OR] [BC] [E3] [CBS] [1] [SuPS] Identify Severe but Plausible Scenarios

Written by Moh Heng Goh | Apr 16, 2026 7:37:39 PM

CBS-1 Deposit & Account Services

Introduction

For Bank of Commerce, identifying Severe but Plausible Scenarios (SbPS) for CBS-1 Deposit and Account Services is a critical step in operational resilience.

These scenarios are not hypothetical extremes but credible disruption events that could realistically occur and significantly impact the bank’s ability to deliver essential deposit services.

According to BCM Institute guidance, SBPS should test the resilience of critical business services against a combination of operational, cyber, third-party, and environmental disruptions, ensuring that the organisation can remain within its defined impact tolerances.

Aligned with BSP Circular No. 1203 (2024), banks in the Philippines are required to conduct scenario testing using severe but plausible disruptions, including cyber incidents, technology failures, and third-party outages.

The scenarios below are designed to reflect Bank of Commerce’s operating environment, including reliance on core banking systems, digital banking channels, ATM/card networks (e.g., BancNet/Mastercard), telecom infrastructure, and third-party vendors.

Each scenario also integrates Cyber and ICT risks, as required by regulators, and includes proactive risk management actions to demonstrate preparedness.

Table P5: Identify Severe but Plausible Scenarios for CBS-1

Sub-CBS Code	Sub-CBS	Severe but Plausible Scenario	Impact / Effect	Proactive Risk Management Action	Link to Integration of Cyber and ICT Risks
1.1	Customer Onboarding and Account Application	Branch system outage during peak onboarding period	Delayed account opening; backlog of applications	Implement offline onboarding forms and batch upload capability	ICT system outage, endpoint failure
1.2	Customer Identification and Verification (KYC/CDD)	KYC/AML screening system unavailable due to vendor outage	Inability to verify customers; onboarding halted	Maintain backup screening procedures and alternate provider access	Third-party system failure, cyber dependency
1.3	Account Approval and Opening	Workflow system failure or database corruption	Accounts cannot be activated; service delays	Enable manual approval and post-recovery reconciliation	Core system failure, data integrity risk
1.4	Initial Funding and Deposit Booking	Core banking outage during deposit transactions	Funds not credited; customer dissatisfaction	Activate manual receipting and deferred posting procedures	Core banking disruption, transaction integrity risk
1.5	Product Setup and Account Parameter Maintenance	Incorrect parameter deployment due to a system error	Wrong fees/interest applied across accounts	Enforce maker-checker controls and rollback procedures	Configuration risk, system change failure
1.6	Deposit Transactions Processing	The core banking system crashed during the peak transaction period	Inability to process deposits/transfers; systemic disruption	Implement active-active DR architecture and transaction replay	Critical ICT failure, high availability risk
1.7	Withdrawal and Funds Access Processing	ATM network outage due to telecom failure	Customers are unable to withdraw cash	Provide branch fallback withdrawals and alternate network routing	Telecom outage, ATM network dependency
1.8	Account Servicing and Customer Maintenance	CRM system unavailable due to a cyber incident	Customer requests are delayed; poor service experience	Enable manual servicing logs and prioritise high-risk requests	Cyberattack, data access disruption
1.9	Interest, Fees, and Charges Processing	Batch processing failure at the end of the day	Incorrect balances or missing interest postings	Re-run batch with validation controls and reconciliation checks	Batch processing risk, system integrity issue
1.10	Statement, Passbook, and Balance Reporting	Reporting system failure or data inconsistency	Customers are unable to view accurate balances/statements	Enable alternate reporting channels and regenerate statements	Data integrity risk, reporting system failure
1.11	Digital Account Access and Channel Integration	A Distributed Denial-of-Service (DDoS) attack on online banking	Customers are unable to log in or transact online	Deploy DDoS protection, traffic filtering, and failover channels	Cyberattack (DDoS), digital channel disruption
1.12	ATM and Card-Based Access Management	Card switch failure or BancNet/Mastercard outage	ATM and POS transactions unavailable	Establish alternate routing and contingency withdrawal processes	Third-party ICT dependency, network failure
1.13	Account Reconciliation and Exception Handling	The reconciliation system failure is causing a backlog of breaks	Unresolved discrepancies affecting financial integrity	Automate reconciliation recovery and prioritise high-value breaks	Data processing failure, system outage
1.14	Dormancy, Holds, and Account Restrictions Management	Failure to apply fraud hold due to system outage	Unauthorised transactions; potential fraud losses	Enable emergency manual hold procedures and escalation	Control system failure, fraud risk
1.15	Fraud Monitoring and Transaction Surveillance	Fraud monitoring system outage during cyberattack	Undetected fraudulent transactions; financial losses	Implement real-time alert backup and manual monitoring escalation	Cybersecurity failure, SIEM disruption
1.16	Complaints, Disputes, and Service Recovery	Call centre system outage during a major incident	Customers are unable to report issues or disputes	Activate alternate communication channels (email, branch)	Telecom failure, communication system outage
1.17	Regulatory Reporting and Compliance Monitoring	Data warehouse failure before the regulatory submission deadline	Inability to submit accurate regulatory reports	Maintain manual reporting templates and escalation protocols	Data system failure, reporting risk
1.18	Business Continuity and Service Recovery for Deposit Services	Data centre outage due to a natural disaster or a cyberattack	Multiple services are disrupted across CBS-1	Activate the DR site, the crisis management team, and recovery procedures	Full ICT infrastructure failure, cyber/physical risk

BSP Circular No. 1203 – Regulatory Requirements and Examples

Under BSP Circular No. 1203, banks are required to:

Conduct Scenario Testing Using Severe but Plausible Events

Banks must test their ability to remain within impact tolerance during disruptions.
Example: Simulate a core banking outage (1.6) during peak payroll processing to assess recovery capability.

Integrate Cyber and ICT Risks into Operational Resilience

Cyber resilience is a key pillar of operational resilience.
Example: Test a DDoS attack on digital banking (1.11) or a fraud system outage (1.15).

Address Third-Party and Public Infrastructure Dependencies

Banks must assess risks from vendors and infrastructure, such as telecom and payment networks.
Example: Simulate BancNet/Mastercard outage (1.12) or telecom failure affecting ATM services (1.7).

Ensure Business Continuity and Recovery Capability

Banks must have plans to recover critical services within tolerance.
Example: Test data centre outage scenario (1.18) with full DR activation.

Protect Customers and Maintain Financial Stability

Scenarios must consider customer harm and systemic impact.
Example: Evaluate the impact of failed deposit posting (1.4) or fraud detection failure (1.15).

The identification of Severe but Plausible Scenarios for CBS-1 Deposit and Account Services enables Bank of Commerce to move from static planning to dynamic resilience testing.

By linking each sub-service to realistic disruption scenarios, the bank can better understand how failures in technology, cyber systems, third parties, or processes may cascade across operations.

This approach ensures that resilience is not only documented but actively validated through testing and continuous improvement.

More importantly, this exercise aligns directly with BSP Circular No. 1203, which emphasises scenario testing, cyber resilience, third-party risk management, and the integration of business continuity.

For Bank of Commerce, the next step is to operationalise these scenarios through structured testing exercises, validate recovery capabilities against defined impact tolerances, and continuously refine controls to ensure that critical deposit services remain available, secure, and reliable—even under severe disruption conditions.

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CBS-1 Deposit & Account Services
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